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The court granted police a request to hold the two men in custody for another seven days while they gather evidence. They are next due to appear on October 31.

Before Tuesday's court hearing Ms Maina's lawyer, George King'ori, who became her legal representative ahead of her death, told AAP the couple was in the midst of divorce proceedings in the Kenyan courts.

The head teacher at Hillcrest Prepatory School in Karen was granted a restraining order against her husband in April.

"She feared he had become irrational," Mr King'Ori told AAP.

Karen police have confirmed to Kenya's The Standard that Mr Maina was being held as the prime suspect in Ms Maina's murder.

"We believe he has information that can help us know how and why she was murdered," Karen OCPD Cunningham Suiyanka told the newspaper.

"He is here with another suspect for interrogation."

Police have also seized and are checking Ms Maina's phone, which was taken by one of her alleged attackers.

Investigators believe she was accosted by three men while walking home after dropping off one of her sons at a friend's home.

A post-mortem revealed she was shot in the neck, with the bullet exiting through her back, authorities said.

Because of the angle of the bullet and marks on her knees, investigators believe she was kneeling at the time.

Ms Maina moved to Nairobi from Sydney in 2015 so her two sons could experience another culture and grow up near her husband's extended family, a friend told AAP this week.

She had taught English and drama for almost five years at Sarah Redfern High School in Sydney.